Taxing the rules
Taxing authorities bring a different dimension when counsel’s client is a target. International transactions that are complex and perhaps unique seem to attract a more eager level of interest, especially if the target has some profile. As noted in an earlier high profile case, it is very important to address the allegations early in the process, if one is to persuade the taxing authority that another interpretation is available for a set of transactions.
First hand information gathering by the forensic accountant is essential for maximum creditability with the tax authorities, so some international travel along with digging for both archived documents and spending time with people who have short memories.
The final step is effective communication with Counsel of your financial findings to ensure that all the authorities ‘misunderstandings’ are identified and addressed in a most professional manner.